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Brussels, 28 April 2003
EURO COOP Comments to the European Commission Consultation Document
on the Battery Directive Revision
EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 3 Central and Eastern European countries. Created in 1957, EURO COOP today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.
EURO COOP welcomes the opportunity provided by the European Commission for all stakeholders to be consulted on the outline of a revised Battery Directive.
EURO COOP believes it is important that the revised Directive aims to achieve a high level of environmental protection.
EURO COOP has the following specific comments to make on the European Commission Consultation Document on the Battery Directive Revision:
Collection and Recycling Targets
EURO COOP welcomes the establishment of collection and recycling targets for all spent batteries and accumulators placed on the Community market since batteries are an important source of pollution.
However, EURO COOP cautions against focusing only on recycling of batteries. Initiatives to tackle the true root of the problem - namely preventing excessive use of batteries - should also be foreseen.
Incentives to promote the use of more environmentally-friendly batteries should therefore be explored.
Schemes to educate and inform consumers to encourage them to adopt more sustainable consumption habits could also be foreseen - such as is currently done by EURO COOP member organisations across Europe.
Producer Responsibility
In order to meet these targets, EURO COOP favours the introduction of a "Producer Responsibility Principle" for spent batteries and accumulators by establishing free take-back system/financing separate collection and recycling facilities.
However, EURO COOP would caution against free take-back systems that require outlets to take-back spent batteries. These systems have had only limited success - as the experience of our member organisations demonstrates - the economics of the battery recycling process do not provide for the batteries to be recycled even when they are separated from the household waste stream. Moreover, in some Member States facilities to collect and recycle batteries are not in place, leaving the responsibility with the outlets . It is therefore important that the Commission consider creating tools to check that Member States fully implement the revised Directive in practice.
EURO COOP would also urge the Commission to consider the possibility of local municipalities together with producers setting-up systems directly with householders.
Although many consumer co-operatives currently choose to participate in free take- back systems, these should be voluntary rather than compulsory.
Voluntary Agreements
EURO COOP does not recommend the introduction of voluntary agreements with producers for collection and recycling of spent batteries and accumulators placed on the Community market as an option to meet the proposed collection and recycling targets. In the past, such systems collapsed as producers did not accept their full responsibilities.
Batteries and Accumulators containing Cadmium
EURO COOP favours the introduction of a ban on the use of cadmium in batteries and accumulators placed on the Community market. However, if any of the other alternatives outlined in the document are chosen, EURO COOP would recommend that a high fee be put on batteries and accumulators containing cadmium.
For further information, contact:
Dónal WALSHE, Secretary General
or
Louise OUSTED OLSEN, Senior Adviser
Tel.: +32.(0)2.285.00.76 - Fax: +32.(0)2.231.07.57 - E-mail: Lousted_Olsen@eurocoop.org
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